A detailed interview with Warsaw-based lawyer Ihor Budihai, published by the expatriate site Finding Poland on 6 March 2026, provides the first practitioner-level analysis of the immigration overhaul that entered into force in stages during 2025 and is now reshaping corporate mobility programmes.
Budihai explains that Article 116 of the amended Act on Foreigners has moved the ‘filter’ to the very start of the process: if an applicant arrives on an entry document that is not expressly listed as compatible with a temporary-residence-and-work permit, provincial offices will refuse to open the case. This affects, for example, holders of student visas from non-accredited colleges and foreigners trying to convert a German residence card into Polish status.
Fees have also risen sharply—work-permit applications lasting more than three months now cost PLN 400, while permits for posted workers cost PLN 800.
![Expert interview unpacks Poland’s new ‘gatekeeping’ immigration model and digital MOS portal]()
Navigating such nuanced rules is rarely straightforward. VisaHQ’s Poland service centre (https://www.visahq.com/poland/) offers end-to-end support—from confirming that a traveller’s entry document satisfies Article 116 to calculating the new statutory fees—so employers can keep assignments on track despite the regulatory upheaval.
At the same time, the EU Blue Card has become more flexible: it is no longer employer-specific, allows side business activity, and carries a six-month job-loss grace period after two years of residence.
Central to the reform is the digital MOS (Moduł Obsługi Spraw) portal. Although the law enabling ‘MOS 2.0’ is on the books, full mandatory e-filing will begin only after the Interior Minister issues a Monitor Polski communiqué—expected later in 2026. Employers should nevertheless prepare to upload scanned copies of every passport page and keep original documents ready for spot inspections.
For HR and global-mobility teams the take-aways are clear: 1) salary budgets must account for higher statutory fees; 2) compliance teams must verify that assignees hold the exact visa category needed to initiate residence proceedings; 3) document-management systems should be upgraded to handle the upcoming e-filing requirement. Failure to adapt could see applications rejected outright at the ‘admissibility’ stage, leaving talent in legal limbo.
Budihai explains that Article 116 of the amended Act on Foreigners has moved the ‘filter’ to the very start of the process: if an applicant arrives on an entry document that is not expressly listed as compatible with a temporary-residence-and-work permit, provincial offices will refuse to open the case. This affects, for example, holders of student visas from non-accredited colleges and foreigners trying to convert a German residence card into Polish status.
Fees have also risen sharply—work-permit applications lasting more than three months now cost PLN 400, while permits for posted workers cost PLN 800.
Navigating such nuanced rules is rarely straightforward. VisaHQ’s Poland service centre (https://www.visahq.com/poland/) offers end-to-end support—from confirming that a traveller’s entry document satisfies Article 116 to calculating the new statutory fees—so employers can keep assignments on track despite the regulatory upheaval.
At the same time, the EU Blue Card has become more flexible: it is no longer employer-specific, allows side business activity, and carries a six-month job-loss grace period after two years of residence.
Central to the reform is the digital MOS (Moduł Obsługi Spraw) portal. Although the law enabling ‘MOS 2.0’ is on the books, full mandatory e-filing will begin only after the Interior Minister issues a Monitor Polski communiqué—expected later in 2026. Employers should nevertheless prepare to upload scanned copies of every passport page and keep original documents ready for spot inspections.
For HR and global-mobility teams the take-aways are clear: 1) salary budgets must account for higher statutory fees; 2) compliance teams must verify that assignees hold the exact visa category needed to initiate residence proceedings; 3) document-management systems should be upgraded to handle the upcoming e-filing requirement. Failure to adapt could see applications rejected outright at the ‘admissibility’ stage, leaving talent in legal limbo.
